Issues: (i) Whether the Serious Fraud Investigation Office can issue a Look Out Circular while conducting an investigation under Section 212 of the Companies Act, 2013; (ii) whether a bank can issue a Look Out Circular without first classifying the borrower's account as fraud under the Reserve Bank of India's fraud directions.

Issue (i): Whether the Serious Fraud Investigation Office can issue a Look Out Circular while conducting an investigation under Section 212 of the Companies Act, 2013

Analysis: The investigation under Section 212 is directed at suspected fraud in the affairs of a company and includes powers to investigate cognizable offences under Section 447. The Look Out Circular was issued after the company had been brought within the investigative framework under the Companies Act, 2013 and after the resolution professional's report had led to authorisation of investigation. The governing office memorandum permitted issuance of a Look Out Circular by the SFIO in cases involving cognizable offences and, in exceptional cases, where the economic interest of India was at stake. The Court held that the investigation concerned serious economic offences, that public interest was involved, and that the presence of the respondents was necessary for effective investigation.

Conclusion: The issue was answered in the affirmative and in favour of the SFIO.

Issue (ii): Whether a bank can issue a Look Out Circular without first classifying the borrower's account as fraud under the Reserve Bank of India's fraud directions

Analysis: The Court distinguished between civil consequences flowing from fraud classification under the Reserve Bank of India directions and the separate criminal obligation to lodge a complaint where cognizable offences are disclosed. It held that the requirement to classify an account as fraud is not a precondition for lodging a criminal complaint or for seeking a Look Out Circular. The bank had already complained to the investigating agency, and the governing office memorandum permitted a bank to seek issuance of a Look Out Circular where cognizable offences were involved. The Court further held that waiting for completion of fraud-classification proceedings would defeat the object of preventing persons involved from leaving the country while criminal investigation was pending.

Conclusion: The issue was answered in the affirmative and in favour of the Bank.

Final Conclusion: The impugned judgment was set aside, and the connected appeals were disposed of with directions for criminal law enforcement to proceed on the bank's complaint and for investigation to continue in accordance with law.

Ratio Decidendi: A Look Out Circular may validly be issued in aid of a pending investigation into cognizable economic offences without waiting for conclusion of civil fraud-classification proceedings, and the existence of criminal liability under the Companies Act, 2013 is sufficient to attract the governing LOC guidelines.

Issues: (i) whether an interim injunction under Section 9 of the Arbitration and Conciliation Act, 1996 could restrain the company from convening board and general meetings to consider removal of a director; (ii) whether the notices for the meetings were vitiated for non-compliance with the notice and hearing requirements under Sections 169 and 173(3) of the Companies Act, 2013; (iii) whether the impugned order satisfied the settled requirements for grant of interim relief.

Issue (i): whether an interim injunction under Section 9 of the Arbitration and Conciliation Act, 1996 could restrain the company from convening board and general meetings to consider removal of a director.

Analysis: The relief granted by the court below effectively prevented the company from exercising its statutory and internal governance powers to convene meetings and place the proposed removal before the shareholders. The power under Section 9 is equitable and discretionary, and it is meant to preserve the arbitral subject matter, not to freeze corporate decision-making or confer final relief at the interim stage. The statutory framework governing company meetings permits such meetings to be convened, and judicial interference in the convening of meetings is exceptional.

Conclusion: The injunction restraining the convening of the meetings was not justified.

Issue (ii): whether the notices for the meetings were vitiated for non-compliance with the notice and hearing requirements under Sections 169 and 173(3) of the Companies Act, 2013.

Analysis: Section 169 requires a reasonable opportunity of being heard before removal of a director, while Section 173(3) prescribes seven days' notice for board meetings but also permits shorter notice for urgent business, subject to statutory conditions. The court found that the impugned order placed undue emphasis on the short notice allegation without properly accounting for the urgency of the business and the statutory exception permitting shorter notice. The legality of the proposed meeting could not be pre-emptively interdicted merely on the basis of such challenge.

Conclusion: The notices were not shown to be so defective as to warrant an injunction restraining the meetings.

Issue (iii): whether the impugned order satisfied the settled requirements for grant of interim relief.

Analysis: The order below did not record clear findings on prima facie case, balance of convenience, or irreparable harm. Instead, it restrained the company from proceeding with the meetings in a manner that amounted to a pre-emptive adjudication of contested facts and an impermissible interference with corporate functioning. The statutory and equitable tests for interim protection were therefore not properly applied.

Conclusion: The requirements for interim relief were not met.

Final Conclusion: The appellate court set aside the restraint order and left the parties to pursue their remedies in accordance with law, including the statutory company-law framework and arbitration.

Ratio Decidendi: An interim order under Section 9 of the Arbitration and Conciliation Act, 1996 cannot be used to pre-emptively restrain corporate meetings or the exercise of statutory governance powers unless the established tests for interim relief are clearly satisfied and the statutory scheme is shown to be violated in a manner warranting such exceptional interference.

Issues: (i) Whether investments made by the borrower in subsidiaries could be treated as diversion or siphoning of funds when the investments were found to have been made from internal accruals and cash surpluses, and not from borrowed funds. (ii) Whether a declaration of wilful defaulter could stand when the show-cause and the eventual decision were founded solely on the forensic audit report without independent objective assessment of the source of funds and the borrower's track record.

Issue (i): Whether investments made by the borrower in subsidiaries could be treated as diversion or siphoning of funds when the investments were found to have been made from internal accruals and cash surpluses, and not from borrowed funds.

Analysis: The Master Circular treated wilful default under clauses dealing with diversion and siphoning as dependent on misuse of borrowed funds. Diversion and siphoning, as defined in the circular, required borrowed funds to be deployed for purposes other than those for which finance was sanctioned or to be transferred to subsidiaries or unrelated activities. The lender banks' own restructuring documents recorded that the investments in subsidiaries were funded from cash surpluses and not from borrowed monies. Once that factual position stood acknowledged, the core ingredient for invoking the wilful defaulter framework was absent.

Conclusion: The alleged investments did not amount to diversion or siphoning of borrowed funds and could not sustain a wilful defaulter declaration.

Issue (ii): Whether a declaration of wilful defaulter could stand when the show-cause and the eventual decision were founded solely on the forensic audit report without independent objective assessment of the source of funds and the borrower's track record.

Analysis: The circular required a conscious and objective evaluation at each stage, including scrutiny of the borrower's track record, and the default had to be intentional, deliberate and calculated. The forensic audit report itself noted that the source of funds had not been verified, yet it was treated as the sole basis for issuance of notice and for the final declaration. The banks also failed to engage with their own restructuring records, which had earlier treated the transactions as strategic and had not classified the borrower as a diversion case. Such mechanical reliance on an incomplete audit report fell short of the procedure and standard mandated by the circular.

Conclusion: The show-cause process and the wilful defaulter declaration were unsustainable for want of objective application of mind and compliance with the circular.

Final Conclusion: The wilful defaulter findings were legally unsustainable, and the bank's challenge to the quashing of those findings failed.

Ratio Decidendi: A borrower can be branded a wilful defaulter under the RBI framework only where borrowed funds are shown, on an objective and reasoned assessment, to have been intentionally diverted or siphoned off; a declaration based solely on an unverified forensic report, without independent examination of the source of funds and the borrower's overall track record, is invalid.

Issues: Whether additional stamp duty under Section 3B of the Karnataka Stamp Act, 1957 could be levied on an instrument of conveyance approving a scheme of arrangement under Sections 230-232 of the Companies Act, 2013, notwithstanding the maximum duty prescribed in Article 20(4) of the Schedule and the effect of Section 3C of the Karnataka Stamp Act, 1957.

Analysis: The charging provision in Section 3 of the Karnataka Stamp Act, 1957 makes the duty payable the amount specified in the Schedule, while Section 3B creates a distinct levy of additional duty at ten per cent of the duty chargeable on specified instruments. Section 3B(2) expressly provides that the additional duty is in addition to the duty chargeable under Section 3. The maximum amount in Article 20(4) of the Schedule limits only the duty under Section 3 on the instrument of conveyance and does not absorb the separate levy under Section 3B. Section 3C, although couched in non obstante language, operates only to prevent duty under any other law from exceeding the maximum amount chargeable under the Act; it does not curtail the independent levy under Section 3B. The statutory scheme therefore permits the additional cess or stamp duty over and above the capped duty under the Schedule.

Conclusion: The levy of additional stamp duty under Section 3B was valid and was not restricted by the maximum duty prescribed in Article 20(4) or by Section 3C.

Final Conclusion: The challenge to the adjudication of stamp duty failed, and the additional levy was upheld as being within the statutory framework of the Karnataka Stamp Act, 1957.

Ratio Decidendi: Where the statute creates a separate additional duty and expressly states that it is in addition to the duty chargeable under the charging provision, a maximum duty cap in the Schedule does not include or exhaust that additional levy, and a non obstante clause limited to duty under other laws cannot be used to curtail the separate statutory surcharge.

Issues: (i) Whether the appellant was entitled to suspension of the conviction so as to avoid the disqualification arising from his conviction under the Companies Act, and (ii) whether the sentence deserved to be suspended and bail granted pending appeal.

Issue (i): Whether the appellant was entitled to suspension of the conviction so as to avoid the disqualification arising from his conviction under the Companies Act.

Analysis: Suspension of conviction is an exceptional relief and depends on the facts of the case, especially whether refusal to suspend would cause injustice or irreversible consequences. The Court examined the appellant's reliance on the alleged disqualification from office and the claimed prejudice to his corporate position, but found that the conviction arose from his role in the coal block matter, where the evidence on record did not make the conviction prima facie unsustainable. The Court also noted the broader public interest involved in coal block allocation cases and held that the appellant's case did not fall within the category of exceptional circumstances warranting stay of conviction.

Conclusion: The request for suspension of conviction was rejected and was against the appellant.

Issue (ii): Whether the sentence deserved to be suspended and bail granted pending appeal.

Analysis: While declining to stay the conviction, the Court considered the pending appeal, the appellant's age, his family circumstances, the earlier suspension of sentence granted to the co-convict, and the fact that the appellant had not misused liberty during the proceedings. On that footing, the Court found it to suspend the sentence and impose conditions to secure his appearance and conduct during the appeal.

Conclusion: The sentence was suspended and bail was granted, subject to conditions, in favour of the appellant.

Final Conclusion: The conviction continued to operate, but the custodial sentence was suspended, resulting in a partial grant of relief pending the final hearing of the appeal.

Ratio Decidendi: Suspension of conviction is granted only in exceptional cases where refusal would cause irreversible prejudice, and while considering such relief the Court may weigh the nature of the offence, the public interest involved, and the statutory disqualification that would follow from the conviction.

1. Whether the Company Court has the jurisdiction and authority under the Companies Act, 2013 to direct the Serious Fraud Investigation Office (SFIO) to investigate the affairs of a company.

2. Whether the reference to the SFIO by the Company Court without a prior order or direction from the Central Government is legally valid.

3. The scope and necessity of investigation into alleged misfeasance, malfeasance, and diversion of funds by the company and its subsidiaries.

4. The legal effect and binding nature of a Company Court order directing investigation under Section 210(2) of the Companies Act, 2013 on the Central Government.

5. The permissibility and implications of appointment of a forensic auditor by the parties, and the relationship of such appointment to the SFIO investigation.

6. The impact of a status quo order on the commencement and continuation of investigation by the SFIO.

7. Whether allegations made by minority shareholders with negligible shareholding should be entertained in the context of investigation and administration of the company.

8. The procedural propriety and legal consequences of the Central Government ordering an investigation under Section 212(1)(c) of the Companies Act, 2013 in public interest.

9. Whether the investigation by SFIO overlaps or conflicts with prior closure of complaints by the Official Liquidator and Regional Director.

10. The consequences of non-payment of forensic audit costs by the party requesting such audit and its impact on investigation process.

Issue 1 & 2: Jurisdiction and Authority of Company Court to Direct SFIO Investigation

- Relevant Legal Framework: Sections 210 to 213 of the Companies Act, 2013 govern investigation into affairs of companies, including the role of the Central Government and SFIO. Section 210(2) mandates the Central Government to order investigation where a Court or Tribunal has ordered so. Section 212 allows the Central Government to assign investigation to SFIO on various grounds.

- Court's Interpretation and Reasoning: The Court held that the Company Court, defined under Section 2(29) as the High Court with jurisdiction over the company's registered office, has the power to direct investigation under Section 210(2). Such direction binds the Central Government, which must order investigation accordingly. The Court rejected the contention that only the Central Government can initiate SFIO investigation, emphasizing that the Company Court's order is binding and a valid basis for investigation.

- Precedents and Authority: The Court referred to decisions of the National Company Law Appellate Tribunal (NCLAT) and various High Courts, which consistently held that the Central Government's satisfaction is primary but must follow a Court order under Section 210(2). The Court also noted that NCLAT's power is limited to referring matters to the Central Government, which then decides on investigation.

- Conclusion: The Company Court's order directing SFIO investigation is legally valid and binding on the Central Government, thereby confirming the jurisdiction and authority of the Company Court to make such reference.

Issue 3 & 9: Necessity and Scope of Investigation into Alleged Misfeasance and Malfeasance

- Key Evidence and Findings: The Court extensively reviewed the Administrator's reports and findings, which detailed allegations of diversion of funds, fraudulent financial transactions, mismanagement of subsidiaries, and criminal investigations by SEBI, CBI, Enforcement Directorate, and other agencies. The Administrator's interim and final reports revealed high-value fund transfers with unclear utilization, involvement of promoters and employees in siphoning funds, and litigation in USA courts.

- Court's Reasoning: Given the complexity, cross-border nature, and serious allegations involving multiple agencies, the Court found that a normal independent or forensic audit would be insufficient. The SFIO, with its expertise in law, accountancy, forensic investigation, IT, and taxation, was deemed the appropriate agency to conduct a detailed and in-depth investigation.

- Treatment of Competing Arguments: The appellant argued that prior complaints had been closed by the Official Liquidator and Regional Director, and that forensic audit attempts failed due to non-payment. The Court held that such prior closure does not preclude a more comprehensive SFIO investigation. The failure of forensic audit was noted but not considered a bar to SFIO's probe.

- Conclusion: A detailed SFIO investigation is necessary and appropriate to uncover the truth regarding alleged frauds, misfeasance, and malfeasance affecting the company and its subsidiaries.

Issue 4: Binding Effect of Company Court's Direction on Central Government

- Legal Framework: Section 210(2) uses the word "shall" indicating a mandatory obligation on the Central Government to order investigation upon Court or Tribunal direction.

- Court's Interpretation: The Court emphasized that the Central Government is legally bound to order investigation once the Company Court has passed an order to that effect. This statutory mandate removes discretion from the Central Government in such cases.

- Conclusion: The Central Government's subsequent order initiating investigation under Section 212(1)(c) following the Company Court's direction is in accordance with statutory mandate and valid.

Issue 5 & 10: Appointment of Forensic Auditor and Its Relationship to SFIO Investigation

- Facts: The parties had agreed to appoint a forensic auditor at the cost of the party requesting such audit. The forensic audit did not proceed due to non-payment by the requesting party.

- Court's Reasoning: The Court noted that the forensic audit was a separate and less comprehensive process compared to the SFIO investigation. The failure to remit costs and consequent non-commencement of forensic audit did not affect the SFIO's mandate or investigation.

- Conclusion: The forensic audit appointment and its failure do not impede or substitute the SFIO's statutory investigation, which is broader and mandated by law.

Issue 6: Impact of Status Quo Order on SFIO Investigation

- Facts: A status quo order had been passed by the Court prior to the Central Government's order directing SFIO investigation. The appellant contended that SFIO's commencement of investigation violated the status quo.

- Court's Reasoning: The Court acknowledged that commencement of investigation in the face of a status quo order was inappropriate. However, given the serious allegations and the binding nature of the Company Court's direction, coupled with the Central Government's independent examination and order, the Court preferred to decide the matter on merits rather than procedural violation. The Official Liquidator was directed to explain the breach, with contempt proceedings contemplated.

- Conclusion: The status quo order does not invalidate the investigation but procedural compliance must be ensured going forward.

Issue 7: Relevance of Minority Shareholders' Allegations

- Facts: The appellant argued that allegations were made by shareholders holding negligible shareholding and should not be encouraged.

- Court's Reasoning: The Court did not give weight to the quantum of shareholding in deciding the necessity of investigation. The allegations were supported by Administrator's reports and independent findings, thus warranting investigation regardless of the complainants' shareholding percentage.

- Conclusion: The merit of allegations and evidence is paramount over the shareholding quantum in determining investigation necessity.

Issue 8: Procedural Legitimacy of Central Government's Investigation Order under Section 212(1)(c)

- Legal Framework: Section 212(1)(c) empowers the Central Government to order investigation by SFIO in public interest.

- Court's Findings: The Central Government's order dated 18.06.2025 was issued after examination of the Company Court's order and related reports, expressing opinion that investigation was necessary in public interest. The order specified the scope, powers, and timeline of investigation, consistent with statutory provisions.

- Conclusion: The Central Government's order directing SFIO investigation is procedurally valid and in accordance with the Companies Act, 2013.

Issue 9 (Revisited): Overlap with Prior Closure of Complaints

- Facts: Prior complaints filed by shareholders' forum had been closed by Official Liquidator and Regional Director.

- Court's Reasoning: The Court held that such closure does not preclude a more detailed and statutory investigation by SFIO. The SFIO's investigation is broader and empowered to access records and conduct inquiries beyond the scope of prior complaints.

- Conclusion: Prior closure of complaints does not bar SFIO investigation.

Issue 10 (Revisited): Non-payment of Forensic Audit Costs

- Court's Reasoning: The inability of the party requesting forensic audit to pay costs led to failure of forensic audit process but does not affect the statutory investigation by SFIO.

- Conclusion: Non-payment of forensic audit costs is irrelevant to the SFIO investigation mandate.

Additional Observations and Conclusions

- The Administrator's detailed reports, including forensic audit findings, revealed systemic siphoning of funds, fraudulent transactions involving promoters and employees, and mismanagement of subsidiaries including cross-border entities.

- The Court emphasized the importance of SFIO's multi-disciplinary expertise to uncover complex frauds affecting the root of the economy.

- The Court directed the SFIO to complete preliminary investigation within two months and submit report to Company Court for further proceedings.

- The Court dismissed the appeals and closed connected petitions, with no costs.

ISSUES:

Whether Circular No. 13/2019 dated 29.10.2019 extended the due date for filing financial statements (e-forms AOC-4, AOC-4 (CFS), AOC-4 XBRL) without levy of additional fees up to 30.11.2019.Whether additional fees for delayed filing of financial statements should be levied from the original due date (30 days from AGM) or from the extended due date provided by the Circular.Whether the Circular can override or amend the statutory time limits prescribed under Section 137(1) and Section 403 of the Companies Act, 2013.The scope and applicability of Section 403 and its proviso regarding payment of additional fees for delayed filing under Sections 92 and 137 of the Companies Act, 2013.Whether the appellants are entitled to refund of excess additional fees charged for the period between the original due date and the extended due date granted by the Circular.

RULINGS / HOLDINGS:

The Circular No. 13/2019 dated 29.10.2019 did extend the due date for filing specified financial statements up to 30.11.2019 without levy of additional fees, thereby conferring an entitlement to companies to file within this extended period free of additional fee.Additional fees for delayed filing are leviable only from 01.12.2019 onwards and not from the original due date of 29.10.2019, as per the extension granted by the Circular.The Circular does not amend the statutory provisions but operates under the proviso to sub-section (1) of Section 403 of the Companies Act, which expressly permits submission beyond the prescribed period on payment of additional fees, thereby allowing extension of time.The proviso to Section 403(1) is an exception to the strict timelines and empowers the authority to extend the filing period subject to payment of additional fees, which the Circular exercises.The appellants are entitled to refund of the excess additional fees charged for the period between 29.10.2019 and 30.11.2019, as no additional fee was payable for that period under the Circular's extension.

RATIONALE:

The Court applied the provisions of Section 137(1) of the Companies Act, 2013, which mandates filing of financial statements within 30 days of the AGM, and Section 403(1) which prescribes fees for filing within prescribed time.The proviso to Section 403(1) was critically analyzed, which allows filing beyond the prescribed period on payment of additional fees, thus providing statutory authority for extension of filing deadlines.The Circular No. 13/2019 was interpreted as an exercise of power under the proviso to Section 403(1), granting a specific extension of time without additional fees up to 30.11.2019 for the relevant financial year filings.The learned Single Judge's interpretation that no administrative Circular can amend statutory provisions was rejected, as the Circular operates within the statutory framework and proviso exceptions.The Court emphasized that the extension period granted by the Circular must be recognized for waiver of additional fees, and additional fees are only payable for delays beyond the extended date.No dissent or doctrinal shift was indicated; the decision clarifies the interplay between statutory provisions and administrative Circulars regarding filing timelines and fees.

ISSUES:

Whether the requirement of providing Unique Document Identification Number (UDIN) by full-time Chartered Accountants for documents relating to audit reports and financial statements is manifestly implicit in the tender conditions.Whether the disqualification of a bidder's tender on the ground of non-furnishing of UDIN, when such requirement is not expressly mentioned in the tender notice, is arbitrary, illegal, or violative of constitutional provisions including Articles 14, 19, 21, and 300A of the Constitution of India.Whether tender conditions must explicitly state all mandatory requirements or whether certain statutory or regulatory mandates can be considered implicitly incorporated.The extent of judicial interference permissible in government contracts and tender processes, particularly regarding technical bid evaluation.

RULINGS / HOLDINGS:

The Court held that the requirement of mentioning UDIN in audited financial statements and certificates issued by Chartered Accountants is "manifestly implicit in the Tender Conditions" and "indispensable," notwithstanding the absence of an express clause in the tender document.The rejection of the petitioner's bid on the ground of non-furnishing of UDIN was neither "discriminatory nor illegal or arbitrary" as UDIN generation is mandated by the Institute of Chartered Accountants of India (ICAI) and supported by statutory guidelines and notifications.The Court emphasized that tender conditions need not expressly mention requirements that are mandated by statutory or regulatory authorities, and such mandates are deemed incorporated by necessary implication.Judicial interference in government contracts is limited; the Court recognized the necessity for "reasonable amount of flexibility and 'play in the joints'" in commercial contracts and tender evaluations, and found no grounds for interference in the present case.

RATIONALE:

The Court applied the legal framework established by the Institute of Chartered Accountants of India (ICAI) through its statutory authority under the Chartered Accountants Act, 1949, which mandates generation of UDIN for all certificates, audit reports, and financial statements signed by full-time practicing Chartered Accountants since 2019.The Court relied on the ICAI's Notification dated 02.08.2019 and the detailed briefing on the UDIN system, which aims to "curb malpractices" such as false certification and forgery, and to provide a "universal verification mechanism" enhancing authenticity and trust in financial documents.Precedent decisions from Division Benches of the High Courts of Uttarakhand and Allahabad were followed, which upheld the implicit incorporation of UDIN requirements in tender conditions and justified rejection of bids lacking UDIN-compliant documents.The Court noted that the tender conditions required submission of audited financial statements certified by Chartered Accountants, and since UDIN is mandatory for such certificates under the ICAI regime, the requirement is "manifestly implicit" and need not be expressly stated.The Court rejected the petitioner's argument that absence of explicit mention of UDIN in the tender document rendered the disqualification arbitrary, emphasizing that statutory mandates applicable to tender submissions are binding on bidders.There was no dissent or doctrinal shift; the judgment aligns with established principles limiting judicial interference in government procurement and respecting regulatory frameworks governing professional certifications.

ISSUES:

Whether the relocation of the National Company Law Tribunal (NCLT), Kolkata Bench, to a new premises constitutes a violation of judicial independence and the doctrine of separation of powers.Whether the writ petition under Article 226 of the Constitution of India is maintainable on grounds of inconvenience and alleged infrastructural deficiencies.Whether the judiciary can interfere with executive decisions relating to administrative matters such as allocation of infrastructure and location of tribunals.Whether the appellants have locus standi and have demonstrated violation of fundamental rights to invoke writ jurisdiction in this matter.Whether the impugned order of the Single Judge directing provision of basic facilities and amenities to NCLT advocates is sustainable in law.

RULINGS / HOLDINGS:

The Court held that the relocation of the NCLT, Kolkata Bench, falls within the domain of administrative discretion and policy formulation by the executive, and the judiciary must exercise restraint in interfering with such decisions absent demonstrable illegality, arbitrariness or violation of constitutional or statutory rights.The writ petition was found not maintainable as the appellants failed to demonstrate any violation of fundamental rights or legal injury; mere inconvenience does not constitute locus standi for invoking writ jurisdiction under Article 226.The Court ruled that the judiciary cannot substitute its own judgment for that of the competent authorities in matters of infrastructure allocation and tribunal location, as these are executive functions.The impugned order of the Single Judge was set aside to the extent it interfered with administrative and policy matters, as such interference would amount to micro-managing executive decisions.The Court acknowledged the importance of judicial independence as per the doctrine of separation of powers and binding precedents, but found no violation in the relocation decision as there was no material indicating mala fides or arbitrariness.

RATIONALE:

The Court applied constitutional principles including Article 226 of the Constitution of India, the doctrine of separation of powers, and the mandate of judicial independence as elucidated in the landmark judgment of Union of India v. Madras Bar Association.It relied on the Supreme Court's ruling in Swiss Ribbons Private Ltd. & Anr. v. Union of India regarding administrative control of tribunals and the necessity for tribunals to function independently, but recognized that administrative decisions such as tribunal location remain within executive competence.The Court emphasized judicial restraint in matters of administrative policy, noting that the judiciary's role is not to interfere unless there is clear arbitrariness or constitutional violation.The decision referenced recent Supreme Court authority underscoring that mandamus cannot be issued to direct the functioning of a tribunal from a particular location, reinforcing the executive's discretion in such matters.While acknowledging the appellants' concerns regarding facilities and autonomy, the Court found no evidence of mala fide intent or violation of judicial independence sufficient to warrant judicial intervention.